The Arms Trucking Co. v. WCAB (Eichenberger), The Arms Trucking Co. v. WCAB (Eichenberger)

Claimant, a truck driver, suffered a work-related fall on July 7, 2011 and filed a Claim Petition for left shoulder impingement syndrome; parties executed an Agreement acknowledging the July 7, 2011 shoulder injury.
Claimant subsequently filed a Review Petition seeking amendment of the injury description to include aggravation of a pre‑existing degenerative cervical condition.
Claimant underwent shoulder surgery and reported ongoing left arm/shoulder pain and stiffness; he also received chemotherapy beginning November 2011 for non‑Hodgkin’s lymphoma (maintenance through 2014).
Multiple medical experts (treating and employer experts) submitted reports addressing causation, disability, and recovery; treating doctors attributed persistent left shoulder and brachial plexus impairment to the July 7, 2011 fall and one treating physician opined the cervical condition was aggravated by that event.
The WCJ found Claimant and treating physicians credible, awarded temporary total disability (TTD) benefits from July 7, 2011 through December 10, 2012, and expanded the work injury to include aggravation of Claimant’s pre‑existing neck condition.
The Board affirmed the WCJ; Employer appealed to this Court, which affirmed the Board’s order.

Issue	Claimant's Argument	Employer's Argument	Held
Whether Claimant was entitled to TTD benefits from July 7, 2011 through Dec. 10, 2012	Work injury substantially contributed to disability; medical testimony supports inability to work due to shoulder/brachial plexus injury	Claimant’s chemotherapy was the cause of total disability during that period, so WC benefits should be denied	Affirmed: WCJ’s credibility findings and medical evidence support that the work injury was a substantial contributing factor to the disability, so TTD awarded
Whether the work injury description may be expanded to include aggravation of pre‑existing cervical condition	Treating physician unequivocally opined, based on history and records, that the July 2011 event aggravated pre‑existing degenerative cervical disease	Employer: medical testimony was equivocal and did not establish causal connection to the work event	Affirmed: the court held Dr. Levy’s report, read in full, constituted unequivocal medical testimony supporting expansion to include aggravation of the cervical condition

Pa. State Univ. v. Workers’ Comp. Appeal Bd., 53 A.3d 126 (Pa. Cmwlth. 2012) (standard for medical causation and requirement that testimony permit a valid inference of causation)
Thomas Lindstrom Co. v. Workers’ Comp. Appeal Bd., 992 A.2d 961 (Pa. Cmwlth. 2010) (treatment of causation language in medical testimony)
Bemis v. Workers’ Comp. Appeal Bd., 35 A.3d 69 (Pa. Cmwlth. 2011) (medical qualifiers do not render opinion equivocal if testimony read as a whole is unequivocal)
Amandeo v. Workers’ Comp. Appeal Bd., 37 A.3d 72 (Pa. Cmwlth. 2012) (definition of unequivocal medical testimony)
Dietz v. Workers’ Comp. Appeal Bd., 126 A.3d 1025 (Pa. Cmwlth. 2015) (unequivocal medical testimony required when causal connection is not obvious)